{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Active management, use of derivatives for investment purposes, exposure to emerging markets bonds, including labelled green/social/sustainable bonds, which may have complex credit and liquidity profiles",
    "classification": "non-complex",
    "supporting_data": "The Sub-Fund is a UCITS ETF, which is generally presumed non-complex under MiFID II Article 25(4)(a)(iv)[1]. It is actively managed and may use derivatives for efficient portfolio management and for investment purposes to seek increased return, but there is no indication that derivatives are central to the strategy (e.g., no synthetic replication or significant use of swaps). The ETF primarily invests in fixed income securities of emerging markets, including labelled bonds, which are transparent in their use of proceeds but may carry higher credit, liquidity, and emerging market risks. The ETF references a transparent index (J.P. Morgan EM Credit Green, Social and Sustainability Bond Diversified Index) and provides daily disclosure of holdings. The risk profile is category 4 (moderate), reflecting market and credit risks typical of fixed income, not structural complexity. There is no evidence of embedded derivatives, contingent convertibles, or other features that would make the product difficult for a retail investor to understand. The use of derivatives appears limited and for risk management or return enhancement, not as a core, opaque strategy. Therefore, despite active management and some derivative use, the ETF does not exhibit the structural complexity or opacity that would override the UCITS presumption of non-complexity under MiFID II[1]. If the derivative use were more integral (e.g., synthetic replication, significant swap exposure), or if the underlying bonds were themselves complex structured products (e.g., CLOs), the classification might differ, but based on the provided information, such features are not present."
}